Consumer Protection Regulation for Low Access Environments Smart Campaign Isabelle Barrès

Stability of the financial system, access to financial services, job creation, development of micro, small and medium enterprises, etc. Inter disciplinary questions  Client protection regulation and supervision  Norms and codes of conduct for the industry  Financial education for clients Regulators (Central Banks, Governments, Client protection agencies) clients) Codes of conduct, voluntary involvement of financial service providers Clients (individuals or entreprises) and client protection agencies 3 pillars Actors Technical and financial partners Client Protection: 3 pillars

Client Protection Principles 1.Appropriate product design and delivery 2.Prevention of over-indebtedness 3.Transparency 4.Responsible pricing 5.Fair and respectful treatment of clients 6.Privacy of clients data 7.Mechanisms for complaint resolution

Client Protection Standards Appropriate Product Design and Delivery Channels 1.The FI designs products that are appropriate to client needs and do no harm 2.The FI seeks client feedback for product design and delivery 3.The FI does not have aggressive sales techniques Prevention of Over- indebtedness 1.The FI conducts appropriate client repayment capacity analysis before disbursing a loan 2.The FI incentivizes quality loans 3.The FI uses credit bureau and competitor data, as feasible in local context 4.The FI Management and Board is aware of and concerned about the risk of over-indebtedness 5.The FI's internal audit department monitors that policies to prevent over- indebtedness are applied 6.The FI avoids dangerous commercial practices (i.e., combining loan products to meet the same need, or restricting the loan use; sets prudent limits to allow for the renewal of a loan in case of early repayment; sets guidelines for appropriate rescheduling policies)

Client Protection Standards Transparency 1.The FI fully discloses cost and non-cost information 2.The FI communicates proactively with clients in a way that clients can easily understand 3.The FI uses a variety of disclosure mechanisms 4.The FI leaves adequate time for client review and discloses at multiple times 5.The FI provides accurate and timely account information Responsible Pricing1.The FI offers market-based, non-discriminatory pricing 2.The FI’s efficiency is in line with its peers 3.The FI does not use excessive penalty fees

Client Protection Standards Fair and Respectful Treatment of Clients 1.The FI culture raises awareness and concern about fair and responsible treatment of clients 2.The FI has defined in specific detail what it considers to be appropriate debt collection practices 3.The FI's HE policies (recruitment, training) are aligned around fair and responsible treatment of clients 4.The FI implements policies to promote ethics and prevent fraud 5.In selection and treatment of clients, the FI does not discriminate inappropriately against certain categories of clients 6.In-house and 3rd party collections staff are expected to follow the same practices as the FI staff 7.The FI informs clients of their rights

Client Protection Standards Privacy of Client Data 1.The FI has a privacy policy and appropriate technology systems 2.The FI informs clients about when and how their data is shared and gets their consent Mechanisms for Complaints Resolution 1.The FI's clients are aware of how to submit complaints 2.The FI's staff is trained to handle complaints 3.The FI's complaints resolution system is active and effective 4.The FI uses client feedback to improve practices and products